New Zealand Regulator Relieves Health & Life Insurers of Climate Reporting Obligations Pending Law Change

Key Takeaways

• FMA Grants Interim Relief: New Zealand's Financial Markets Authority will take a no-action approach toward health and life insurers that do not lodge climate statements for the 2025/2026 reporting period.
• Government Plans to Remove Insurers from Regime: The relief follows a government announcement that health and life insurers will be removed from the climate-related disclosures framework and will no longer be required to produce annual climate statements.
• Relief Applies Automatically: Insurers with balance dates from March 31, 2026 onward do not need to file climate statements, apply for relief, or notify the FMA of their reliance on the no-action position.
• Legislation Has Yet to Pass: Climate reporting obligations remain in law until Parliament enacts the proposed amendments, but the FMA has indicated it will not enforce them during the transition period.
• Voluntary Disclosures Remain Subject to Fair Dealing Rules: Insurers that continue publishing climate statements voluntarily will still be subject to the fair dealing provisions of New Zealand's Financial Markets Conduct Act.

Deep Dive

Health and life insurers in New Zealand will not be expected to file climate statements this year after the country's financial regulator moved to ease reporting obligations ahead of a planned legislative overhaul.

The Financial Markets Authority said it will adopt a "no action" approach for insurers expected to be removed from New Zealand's climate-related disclosures regime, allowing them to forgo climate statement lodgements while Parliament considers amendments to the law. The decision follows a recent government announcement that health and life insurers will be excluded from the regime and will no longer be required to produce annual climate statements once the legislation is enacted.

For many insurers, the timing had created an awkward problem. Reporting obligations remained on the books, but the government had already signaled its intention to eliminate them. Firms approaching lodgement deadlines faced the prospect of preparing disclosures that could become redundant within months.

The FMA's response is that it will not pursue enforcement action against affected insurers during the transition.

"We recognize that many life and health insurers will be impacted by the uncertain timeframe in which the amending legislation might be passed," FMA General Counsel Liam Mason said in a statement.

"This approach will avoid unnecessary compliance costs and promote the development of fair, efficient and transparent financial markets."

The relief takes effect on June 19 and applies to life and health insurers with upcoming filing dates for the 2025/2026 reporting period. In practical terms, insurers with balance dates from March 31, 2026 onward will not be required to lodge climate statements.

The regulator said firms will not need to apply for the relief or notify the FMA that they intend to rely on it. The move does not change the law itself. Climate reporting obligations remain in force until Parliament passes the proposed amendments. Instead, the FMA is signaling how it intends to exercise its enforcement powers while the legislation works its way through the process.

The regulator also noted that a no-action position is not equivalent to a legal exemption and does not prevent third parties from pursuing action related to the same conduct. The government has not yet indicated when the legislative changes will be enacted. The FMA said it will continue monitoring progress and could revisit its position if the amendments have not been passed by the time insurers would ordinarily begin preparing disclosures for the 2026/2027 reporting period.

"If changes are not made by the time affected life and health insurers are due to begin preparing statements for the 2026/2027 reporting period, we will revisit this 'no action' approach," Mason said.

Some insurers may continue publishing climate statements voluntarily even after the reporting requirement is removed. The FMA said those disclosures will remain subject to the fair dealing provisions of New Zealand's Financial Markets Conduct Act.

The announcement marks one of the first practical consequences of the government's decision to narrow the scope of New Zealand's climate disclosure framework, which had previously brought large financial institutions and listed entities into one of the world's most comprehensive mandatory reporting regimes.

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